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AI agents and UK consumer law: what the CMA expects of businesses

The Competition and Markets Authority's guidance of 9 March 2026, for any business that lets an AI agent answer, refund, recommend or market.

Checked against the published sources on 2 October 2026.

The short answer

The same rules apply whether a customer deals with a person or an AI agent. A business is responsible for what its AI agent does in the same way as for an employee, even where a supplier designed or provides the agent. Breaking consumer protection law can mean a fine of up to 10 per cent of worldwide turnover and compensation for the customers affected.

Guidance
9 March 2026
Regulator
Competition and Markets Authority
Responsibility
The business, as for an employee
Maximum fine
Up to 10 per cent of worldwide turnover

Four steps

The guidance sets out four things to do.

  • Tell your customers if you use an AI agent, where it might affect their decisions
  • Train the agent to respect statutory rights, avoid misleading and obtain consents
  • Monitor how it performs, with a human in the loop
  • Refine it quickly if there is a problem

Refunds

The guidance uses refunds as an example. The agent needs the Consumer Rights Act 2015 for faulty goods, the Consumer Contracts Regulations 2013 for a change of mind after a distance sale, and the business's own terms, such as an extended returns period. Someone with appropriate experience should regularly review its decisions.

Marketing

Where an agent runs marketing, prices should include all unavoidable charges, paid endorsements should be properly labelled, and offers or price reductions should be genuine.

This page explains what the rule says. It is not legal, regulatory, clinical or financial advice on your own position. Rules change, so read the sources listed beside it, and tell us at hello@wajd.co.uk if something here is out of date.

Learn it properly, free

This guide is the summary. The course teaches it in full, with a video conversation, worked scenarios and a knowledge check after each module. Every module is free to read with no account. A certificate, if you want one once you pass, is £9.

Questions people ask

Who is liable when an AI chatbot gives a customer wrong information?

The business. It is responsible for its AI agent as it is for an employee.

Must customers be told they are talking to AI?

Where the fact might affect their decisions, yes. Customers should not be misled into thinking a real person is serving them.

Our supplier built the agent. Are we still responsible?

Yes. If you do not check that the supplier has trained the agent to comply, you may break the law.

What should we do when the agent gets it wrong?

Act quickly, for example by refining prompts or workflows, especially where many people or vulnerable customers are affected.